To make new preventive services benefits requirements work properly, federal agencies may need to help update coding and billing practices, according to America’s Health Insurance Plans (AHIP.
Carmella Bocchino, an executive vice president at AHIP, Washington, has included that suggestion in a comment on preventive services interim final regulations issued by arms of the U.S. Treasury Department, the U.S. Labor Department and the U.S. Department of Health and Human Services (HHS).
The departments issued the regulations in July to implement sections of the Affordable Care Act, the legislative package that includes the Patient Protection and Affordable Care Act (PPACA).
The Employee Benefits Security Administration (EBSA), part of the Labor Department, has posted public comments on the preventive services regulations on its website. The regulations implement laws that will require non-grandfathered insurance policies and health plans to cover a specified package of preventive services without imposing deductibles or other cost-sharing requirements.
EBSA also has posted public comments on processes for reviewing internal and external appeals of health plan decisions.
EBSA has posted 88 review process comments and 261 preventive services comments.
Many of the individuals who posted comments have asked that federal agencies think about the interests of the patients, providers or other parties that the individuals represent.
The American Academy of Pediatrics, Washington, joined with several other children’s health groups to ask that the agencies include pediatricians and maternity care experts be included in internal and external review processes.
“Children are not little adults, and the appropriate standard of care for pediatric medicine is often quite different than for adult medicine,” Robert Hall writes on behalf of the American Academy of Pediatrics and allied groups. “What may appear to be inappropriate for adults can be medically necessary for children. In addition, the care of pregnant women is also important and very different than care for other populations.”
Many individuals wrote on behalf of chiropractic groups to ask that regulators give carriers more specific guidance regarding appropriate
provider types for covered preventive services.
Bocchino has written to praise Congress and the federal agencies for making coverage of preventive services a priority.
“Health insurance plans have a long history and proven record of offering preventive services to individuals to improve their health and care,” Bocchino writes. “We … reaffirm our commitment to consumers by continuing to support evidence-based preventive services to help reduce the onset or severity of illness or disease.”
AHIP likes provisions in the regulations that limit the scope of the preventive services coverage mandate to services approved by specific federal agencies, such as the U.S. Preventive Services Task Force, Bocchino says.
AHIP also likes the approach the agencies have taken in stating that the rules that will apply to coverage of an office visit will depend on the “primary purpose” of the office visit, Bocchino says.
In an appendix, Bocchino suggests that health insurers may need more guidance regarding appropriate coding and billing practices.
Bocchino is recommending that HHS convene a public workshop to solicit feedback on coding and billing for preventive services.
HHS might decide to establish a voluntary working group of public and private stakeholders to improve approaches for identifying the primary purpose of an office visit, Bocchino says.